Verna Doyel - Page 37

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          attributable solely to Christopher.  See Washington v.                      
          Commissioner, 120 T.C. 137, 147 (2003).  Additionally, the                  
          following factors weighing against relief are present:10  (1) The           
          items giving rise to the deficiencies also are attributable to              
          petitioner, (2) petitioner had “reason to know”, and (3)                    
          petitioner will not suffer economic hardship.  Id.                          
               Petitioner also argues that respondent made blanket “pro               
          forma” denials of Hoyt investor section 6015 claims.  We                    
          disagree.                                                                   
               Respondent’s internal memoranda contemplate that some Hoyt             
          investors would qualify for section 6015 relief.  The memoranda             
          do not reflect a decision to issue blanket denials to all Hoyt              
          investor section 6015 claims.                                               
               Ms. Sneed testified that she processed claims granting                 
          section 6015 relief in other Hoyt investor cases she has                    
          reviewed.  Furthermore, Ms. Sneed credibly testified that she               
          conducted a full, impartial, and fair evaluation of petitioner’s            
          section 6015 claim.                                                         
               The format of the determination letter denying section 6015            
          relief for Hoyt investors was unique to the Hoyt cases.  This               
          format was provided to Ms. Sneed.  Respondent did use uniform               


               10  The absence of factors weighing against equitable relief           
          does not weigh in favor of granting relief--this is merely                  
          neutral.  See Washington v. Commissioner, 120 T.C. 137, 149                 
          (2003) (absence of factor weighing in favor of equitable relief             
          does not weigh against granting equitable relief--it is neutral).           




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